1. Home
  2. |Insights
  3. |OMB Seeks to Jettison Defense CAS Board and De-Couple CAS and TINA

OMB Seeks to Jettison Defense CAS Board and De-Couple CAS and TINA

Client Alert | 1 min read | 06.07.19

In late April, the Office of Management and Budget (OMB) sent a letter to Congress containing a number of legislative proposals to streamline and improve the federal acquisition process for inclusion in the Fiscal Year (FY) 2020 National Defense Authorization Act (NDAA). Two of those proposals relate to the Cost Accounting Standards (CAS). The first calls for the disestablishment of the Defense CAS Board—which was a product of the FY 2017 NDAA—to avoid creating a more complicated CAS regulatory framework. The second would de-link the monetary threshold for CAS from the Truthful Cost or Pricing Data threshold (formerly known as TINA), and increase the basic threshold for CAS applicability from $2 million to $15 million. These are two recommendations that the Section 809 Panel made in Volume II of its Report (the CAS Board is also considering repeal of the provisions establishing the Defense CAS Board and increasing the CAS applicability thresholds).

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...